Legal Opinion

LeVine v. Commissioner

United States Tax Court

Decided April 29, 1955No. Docket Nos. 46961, 46962Published

1. The petitioners were equal partners in an offset printing business which they sold to a corporation wholly owned by them at a stated price exceeding the value of the tangible partnership assets by $ 100,000. During the 28 months of its existence the partnership had acquired and trained a highly skilled group of employees, developed new and efficient techniques, and showed rapidly growing and substantial profits.

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1. The petitioners were equal partners in an offset printing business which they sold to a corporation wholly owned by them at a stated price exceeding the value of the tangible partnership assets by $ 100,000. During the 28 months of its existence the partnership had acquired and trained a highly skilled group of employees, developed new and efficient techniques, and showed rapidly growing and substantial profits. Held, on the facts the partnership transferred to the corporation goodwill and other intangibles of a value of $ 45,000. 2. The petitioners on January 15, 1951, revised upward…

1Opinion of the Court

Sidney V. LeVine and Sadye LeVine, Petitioners, v. Commissioner of Internal Revenue, Respondent. Arthur I. LeVine and Betsy V. LeVine, Petitioners, v. Commissioner of Internal Revenue, Respondent

LeVine v. Commissioner

Docket Nos. 46961, 46962

United States Tax Court

24 T.C. 147; 1955 U.S. Tax Ct. LEXIS 199;

April 29, 1955, Filed

Decisions will be entered under Rule 50.

1. The petitioners were equal partners in an offset printing business which they sold to a corporation wholly owned by them at a stated price exceeding the value of the tangible partnership assets by $ 100,000. During the 28 months…

2Cases cited4 opinions

  1. Bouche v. CommissionerUnited States Tax Court · 1952
  2. Stephan Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
  3. Stephan v. CommissionerUnited States Tax Court · 1951
  4. LeVine v. CommissionerUnited States Tax Court · 1955

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